Comments due by June 12th – please contact the Burns District BLM

May 26, 2019

Spay Project Lead
Burns District, Bureau of Land Management – USDI
28910 Highway 20 West, Hines, OR 97738
email: blm_or_spaystudy@blm.gov

Dear Public Officials:

Having observed the Warm Springs HMA wild horses & wild burros & their legal habitat over a period dating back a number of years & recently during 2016, 2017 & 2018, & having closely followed the relative proportions that your BLM office assigns as “appropriate” for wild horses & wild burros in their half-million-acre Herd Management Area, I exercise my democratic rights to strongly protest both your maintaining the spuriously low Appropriate Management Levels (AMLs) for both the wild horses & the wild burros & your obstinate insistence on conducting wild mare spaying experiments in spite of federal courts ruling against such last year.
Your victims would be those magnificent but depressed/oppressed wild mares & their kin whom you removed from the Warm Springs HMA this past October. Basically you insist on doing the same as you already proposed in 2018 under the Environmental Assessment (EA): DOI-BLM-ORWA-13050-2018-0016-EA. The only difference with the current proposal is that you will not spay pregnant mares & the on-range behavior study of released spayed mares would be monitored not by a USGS study team but through a less formal data gathering by BLM employees. Your revised proposal to conduct these cruel & unwarranted spayings contains only a minor concession to not spay pregnant mares & your follow-up behavioral observations would be less rigorous than in the original 2018 proposal. – This is a defiant & inconsiderate proposal that fails to heed the court judgements against such experiments as well as the deep & widespread outrage that was & continues to be expressed by a large number of Americans, as well as people all over the world.

Remember that these wild horses & wild burros, together with their respective habitats within the legal Warm Springs HMA, are a “public trust” which you, as public officials & servants, are sworn to protect & uphold – not abandon to favor selfish & overbearing interests, including public lands ranchers, etc. These can be expected to attack the naturally living horses & burros & to undermine their legal rights to live upon their legally designated lands in the HMA. After all, these adverse interests are a large part of the reason for the passage of the WFHBA in the first place. Please permit me to remind you that Section 2 c of the Wild Free-Roaming Horses & Burros Act (WFHBA) defines a wild horse & wild burro range, meaning original 1971 legal area, as “the amount of land necessary to sustain an existing herd or herds of wild free-roaming horses and burros … and which is devoted principally but not necessarily exclusively to their welfare in keeping with the multiple use management concept of the public lands.” [Emphasis added.] Also please note that Section 3 a of the WFHBA requires the BLM & USFS to manage wild horses & wild burros so as “to achieve and maintain a thriving natural ecological balance on the public lands” and “at the minimum feasible level.” Both (1) your woefully unfair Appropriate Management Levels for both the wild horses & the wild burros of the Warm Springs HMA; & (2) your insistence upon engaging in gruesome, painful, distressful & even lethal spaying experiments upon the wild mares constitute serious & direct violations of the WFHBA’s true & core intent. I vehemently protest the law-mocking attitude that lies behind these shameless choices! Your proposal would violate 100 wild mares now being held in captivity at the Hines-Oregon BLM Wild Horse Corrals, all of which I personally observed. Of these 100, 28 to 34 would be released back into the Warm Springs HMA seven days after their “ovariectomy-via-colpotomy”. This latter involves the very risky insertion of a vet’s arm & an instrument called an “ecraseur” far into the vagina of the mare in order to physically reach & sever/crush the mares ovaries & cause their removal. I can hardly think of anything more extremely violent & counter to the true spirit of the WFHBA! Even under the most professional of conditions in equine veterinarian hospitals, this often results in much suffering, serious complications & frequent death. So, to perform this out in the field would certainly result in an even more risky & cruel outcome for the mares. Again, this flies in the face of the true and core intent & spirit of the WFHBA.

In its opening preamble, this noble Act declares that: (a) “wild horses and burros are living symbols of the historic and pioneer spirit of the West; (b) “they contribute to the diversity of life forms within the nation and enrich the lives of the American people”; (c) wild free-roaming horses and burros shall be protected from capture, branding, harassment or death”; & (d) “they are to be considered in the area where presently found [1971 as year-round habitat area] as an integral part of the natural system of public lands.” [Emphasis added.] Your proposed very problematic & cruel spay experiments are a clear violation of point (c) above, particularly as pertains to “harassment or death”. Also, the woefully unjust Appropriate Management Levels for these wild horses & wild burros in their half-million-acre HMA are in clear violation of the (d) section above, as these population levels thwart the wild horses’ & wild burros’ natural role & tendency to fill their respective niches within the natural life community. Both of these species have their evolutionary roots in North America & they have many positive mutualistic relationships with many of the native plants & animals of the Warm Springs ecosystem. Their post-gastric digestive system also contributes much more in the way of humus, that vital component of soils, than do the ruminant-digesting herbivores, such as cattle, sheep & deer, which are unfairly favored over the wild equids. These wild equids also disperse more intact seeds than do the ruminants & possess less soil-cutting hooves, ones rounder in shape so as to blunt their impact upon the ground. Consider here the sharp cloven hooves of the heavier cattle that are being bred & put out on public lands today, etc.

As part of my input, I excerpt a section from a recent report of mine that included the Warm Springs HMA:

WARM SPRINGS WH & WB HMA OR0007 (BURNS OR BLM):
HA: 499,457 acres, same as HMA. AML: WH: Low 96 to High 178, for Mean of 137 WHs which corresponds to 3,646 acres per individual wild horse; WB: Low 15 to High 24 for a Mean of 20 WBs, which corresponds to 24,973 acres per individual wild burro! … Unrealistic report of population increases, for WHs between 2014 with 192 to 2015 with 368 WHs for a 92% annual increase; for WB between 2011 with 15 to 2012 with 35 WBs for 133% annual increase. From my field inspection in late October 2018, right after the roundup, it appears that all WHs & WBs had been removed by the helicopter roundup. Though I drove throughout the HMA, entering along many dirt roads, I saw no WHs or WBs & only in one place did I see any sign of WHs having been present a few weeks earlier. However, BLM estimates that 30 WHs & 30 WBs may remain. I made a detailed report on this herd and its HMA habitat for Friends of Animals based on my October field inspection. I took many photos & also visited the traumatized WHs & WBs who had just been gathered & placed into the Wild Horse Corrals in Hines just west of Burns, Oregon. Though magnificent horses & burros, they were very upset & depressed, in spite of being fed & watered. The plan that BLM proposed in February 2019 is as follows: for WHs, to allow only an AML of 96 Low End & for WBs only 15 Low End. In 2016, BLM censused 739 WHs & 49 WBs, which corresponds to 676 acres per individual WH & to 10,193 acres per individual WB! From any truly objective point of view, these are hardly overpopulated! However, BLM officials have … pronounced both the wild horses & the wild burros here to be “overpopulated”, all the while ignoring all the thousands of livestock unnaturally stripping forage in order to accommodate the rancher monopolization of resources … “

Although there are many more germane points to present, I believe the foregoing adequately substantiates my opposition to the wild-horse-disrespectful spaying experiments that have been proposed by the current Burns Oregon BLM Environmental Assessment. It is obvious that the WFHBA is being subverted & mocked by the BLM in its decisions concerning Warm Springs. The mere token, non-viable population levels that are assigned to each of these two “national heritage species” & the grossly lopsided forage allocations that are being given to the cattle ranchers who graze 6,134 head during the most favorable seasons in the West Warm Springs & East Warm Springs grazing allotments – both within the Warm Springs HMA — stridently prove the extreme degree to which the wild horses & wild burros are being illegally deprived of their basic rights within their legal area. For this reason, I strongly call upon your decency & honor to reduce livestock within the Warm Springs HMA & to increase the numbers of wild horses & wild burros that are allowed in this half-million-acre HMA. The current AMLs are not viable, genetically speaking, & these native North American equid species are not being allowed to integrate with the natural public lands ecosystem here, as the law intends. Furthermore, there exist very wise & nature-attuned ways of allowing these animals to attain self-stabilizing populations at genetically viable levels. These enlightened ways also allow them to naturally harmonize, or become ecologically well adapted to their specific region. But for this to happen, we people must first pull in our horns & stop being so self-centered. This will permit us to appreciate & allow these wonderful horses & burros to truly realize the natural & un-monopolized home that the law fully intended for them here. And we will be doing everyone a great favor in the process – including ourselves!

I strongly urge you to release back into their rightful legal home, the Warm Springs HMA, those ca. 845-plus wild horses & wild burros who now languish in the Wild Horse Corrals in Hines. This is still a small number for such a large legal HMA. These unique & valuable horses & burros are full of vitality & contribute positively to this unique & intriguing ecosystem – including through catastrophic wildfire prevention. They must not continue to suffer such injustice & have this be compounded by sadistic spaying operations. Such would be the ultimate betrayal of these highly evolved beings, not to mention the unanimously passed WFHBA and the American people themselves.

I propose a Reserve Design strategy by which we Americans can restore the wild horses & wild burros throughout the West & that would be very applicable to the Warm Springs herds & their HMA. Reserve Design would allow for natural adaptation to occur & for mature social units, or bands & their collective herds, to self-stabilize the equid populations, for the mature equids would suppress reproduction in immature equids, according to Nature’s age-old wisdom. This strategy would involve no longer breaking these social units up by the violent roundups that set back their harmonization & force them into desperate straits. This also relates to the horses & burros being allowed to fill their respective niches. Current policy mars the aesthetic & moral dimensions that underpin all our quality of life in America & tests our integrity, both individually & as a people.

Sincerely,

Craig C. Downer,
Wildlife Ecologist
Wild Horse & Burro Fund
P.O. Box 456,
Minden, NV 89423